Justia Civil Rights Opinion Summaries

A thirteen-year-old student in Brewer, Maine, developed a relationship with a twenty-year-old man, who was a coach associated with her school. Over two years, the man sexually assaulted the student multiple times. During that period, rumors circulated at the local high school about their inappropriate relationship. The student reported these rumors to the principal, denied any truth to them, and the principal took limited follow-up action. Other school staff and a police officer had some interactions with the student and the perpetrator, but no one reported or investigated the abuse at the time. The student, now an adult, later sued various school officials, the school department, a police officer, and others, alleging they failed to protect her from abuse despite being aware of warning signs, and sought relief under federal and Maine law.At the United States District Court for the District of Maine, most claims were dismissed at the pleading stage for failing to state a claim. The remaining claims, including those brought under Title IX and 42 U.S.C. § 1983, were resolved in favor of defendants at summary judgment. The court also dismissed the claims against the unidentified police officer for lack of personal jurisdiction, denied the plaintiff’s request for more time to serve that officer, and later denied leave to amend the complaint to add the officer once identified.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s decisions in all respects. The First Circuit held that the plaintiff’s allegations did not plausibly establish municipal liability under § 1983, nor did they show actual knowledge by school officials sufficient to support a Title IX claim. The appellate court also found no abuse of discretion in the district court’s procedural rulings regarding service of process and amendment of the complaint. View "Hewes v. Gardiner" on Justia Law

In the spring of 2020, three veterans residing at the Soldiers’ Home in Chelsea, Massachusetts, died after contracting COVID-19. The personal representatives of the veterans’ estates filed suit against several Massachusetts state officials responsible for the facility, alleging violations of the veterans’ substantive due process rights under the Fourteenth Amendment. The complaint asserted that the officials failed to protect residents from COVID-19 by not implementing adequate safety protocols and maintaining inhumane living conditions, including lack of sanitation, improper restraint of residents, and exposure to illegal drugs.The United States District Court for the District of Massachusetts reviewed the complaint after the defendants moved to dismiss, arguing that the plaintiffs failed to state a claim for a substantive due process violation and that the officials were entitled to qualified immunity. The District Court granted the motion to dismiss. It held that the plaintiffs had not sufficiently alleged individual involvement by any defendant in the purported misconduct regarding COVID-19, and failed to provide details showing how the named veterans were specifically harmed by the living conditions. The court also found no clearly established legal authority placing the officials on notice that their conduct would violate the veterans’ rights, thus concluding qualified immunity applied.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s judgment. The First Circuit held that the complaint did not plausibly allege that the defendants directly caused the harm suffered by the veterans, nor did it sufficiently invoke exceptions to that requirement. The Court also found that the plaintiffs had not demonstrated a violation of clearly established law and thus, the defendants were entitled to qualified immunity. Consequently, the dismissal of the complaint was affirmed. View "Terenzio v. Urena" on Justia Law

After a fatal school shooting occurred at a high school in Michigan, H.H., an eighth-grade student at a different school, was reported by several classmates to have made threatening comments about possessing or bringing a gun to campus. The school administration, in response to these reports and heightened safety concerns, questioned H.H. with assistance from law enforcement, searched his person, backpack, and locker, and ultimately found no firearm. Despite this, the administration determined that H.H. had violated the school district’s code of conduct and referred him for an expulsion hearing, which resulted in his expulsion for 180 days.Following the expulsion, H.H.’s parents filed a lawsuit in the United States District Court for the Eastern District of Michigan against the school district and various officials. They raised claims under 42 U.S.C. § 1983 for alleged violations of H.H.’s Fourth Amendment rights (unlawful search and seizure), procedural and substantive due process, and also asserted state law tort claims. The district court granted summary judgment in favor of the defendants on all claims, finding no constitutional violations and determining that the defendants were immune from state law liability.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the search and seizure of H.H. were reasonable under the circumstances, given the nature of the reported threat and school safety concerns. It found that the procedures afforded to H.H. during the expulsion process satisfied due process requirements, and there was no evidence of bias or arbitrary conduct by the school board. The court also concluded that the individual defendants were entitled to qualified immunity, and that governmental immunity barred the state tort claims. The Sixth Circuit affirmed the district court’s judgment in full. View "Halasz v. Cass City Public Schools" on Justia Law

The underlying dispute arose after an individual was convicted of a crime in Louisiana, served part of his sentence, and later had his conviction reversed or vacated. Claiming factual innocence, he sought compensation under Louisiana’s wrongful conviction statute, which provides monetary awards to qualifying persons. Prior to filing this petition in state court, he had also initiated a separate federal lawsuit under 42 U.S.C. § 1983, alleging violations of his constitutional rights stemming from the same prosecution and conviction.In the Criminal District Court for the Parish of Orleans, the State requested a stay of the wrongful conviction compensation proceedings, citing Louisiana Code of Civil Procedure article 532. This provision allows a court to stay proceedings when there is a related action in another jurisdiction involving the same parties and occurrence. The State argued that the federal suit should proceed first. The district court denied the motion to stay in open court on March 27, 2025. The State then sought supervisory review from the Louisiana Fourth Circuit Court of Appeal, which also denied relief on April 30, 2025.The Supreme Court of Louisiana reviewed the district court’s denial of the stay. The court examined the statutory differences between the state law compensation claim, which requires proof of factual innocence, and the federal civil rights action, which focuses on constitutional violations by individual actors. Concluding that the district court did not abuse its discretion in refusing to stay the state court proceedings—especially in light of the legislative instruction to decide wrongful conviction claims expeditiously—the Supreme Court of Louisiana affirmed the district court’s decision. The main holding is that denial of the State’s motion to stay the wrongful conviction compensation proceedings was proper under the circumstances. View "Williams v. State" on Justia Law

An inmate at the Jefferson County Jail, who was on suicide watch and housed on the bottom floor of a two-story cell block, suffered a head injury and requested medical attention. A deputy, who was not previously familiar with the inmate, observed her distress and the visible injury. After consulting with a nurse, the deputy prepared to transport the inmate to the medical clinic and remotely unlocked her cell door from the control room. Upon release, the inmate ran upstairs and jumped from the second-story landing, sustaining additional injuries.The United States District Court for the Northern District of Alabama considered the inmate’s claim under 42 U.S.C. § 1983, alleging the deputy was deliberately indifferent to a strong likelihood of self-harm. The district court denied the deputy’s motion for summary judgment based on qualified immunity. It found that a reasonable juror could conclude the deputy violated the inmate's constitutional rights by disregarding the risk of harm in releasing her unsupervised and that the law regarding deliberate indifference to detainee safety was clearly established.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of qualified immunity de novo. The appellate court determined that, although the inmate suffered a serious deprivation, there was insufficient evidence that the deputy was subjectively aware that unlocking the cell presented a substantial suicide risk specific to this inmate. The court found the deputy acted to aid the inmate and did not knowingly disregard a substantial risk of harm. The Eleventh Circuit held the deputy did not violate the inmate’s constitutional rights and was entitled to qualified immunity. It vacated the district court’s order and remanded with instructions to enter summary judgment for the deputy. View "Gantt v. Everett" on Justia Law

A sixteen-year-old boy and his friend were waiting for transportation under a carport near the boy’s home when they were approached by an off-duty Baltimore City police officer who had just returned from firearms training. The officer, dressed in plain clothes and carrying a loaded handgun, questioned the boys about their presence in the neighborhood. After a brief exchange, the officer brandished his gun at “low ready,” causing the boys to fear for their lives. The incident had a lasting traumatic effect on the boy, resulting in emotional distress, behavioral changes, and ultimately leading him to attend a boarding school to distance himself from the event.The boy filed suit under 42 U.S.C. § 1983 and Maryland state law against the officer, the Baltimore Police Department, the Mayor and City Council of Baltimore, and the State of Maryland. All claims against the institutional defendants were dismissed by the United States District Court for the District of Maryland, and some claims against the officer were dismissed at summary judgment. At trial, the district court submitted to the jury both constitutional claims and state law gross negligence claims, including gross negligence in the officer’s capacity as a private person. The jury found for the officer on constitutional claims but found him grossly negligent as a private person, awarding $250,000 in compensatory damages for emotional harm. The officer moved to alter or amend the judgment or for a new trial, arguing lack of notice on the private person claim and excessiveness of damages, but the district court denied the motion.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed. The court held that the complaint sufficiently alleged gross negligence as a private person and that the officer had notice of this claim. The court rejected the officer’s arguments regarding supplemental jurisdiction, plain error in jury instructions, and excessiveness of damages, finding no abuse of discretion or plain error by the district court. The judgment was affirmed. View "Nicholson v. Durant" on Justia Law

A fast-casual restaurant chain hired an individual with arthritis in her knees for a cashier/service-team member position. Prior to starting, she requested to be allowed to sit for five minutes after every ten minutes of standing, due to her medical condition. The restaurant required employees in her role to multitask and maintain mobility throughout their shifts, handling various duties such as operating the register, restocking, cleaning, and serving customers. The employer concluded that her requested accommodation would prevent her from performing essential job functions and did not permit her to begin work until the accommodation issue was resolved.The United States District Court for the Eastern District of Kentucky reviewed the case after the employee sued under the Americans with Disabilities Act (ADA) and the Kentucky Civil Rights Act (KCRA), alleging failure to accommodate her disability and failure to engage in the interactive process. The district court granted summary judgment to the employer, holding that the requested accommodation was not reasonable as a matter of law, and that her claim regarding the interactive process could not proceed without a viable accommodation claim.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court affirmed, holding that the employee’s proposed accommodation—sitting for five minutes after every ten minutes of standing—was not objectively reasonable because it would fundamentally alter essential functions of the cashier/service-team member position, which required continuous mobility and multitasking. The court further held that, because no reasonable accommodation was shown, the claim arising from the employer’s alleged failure to engage in the interactive process also failed as a matter of law. The judgment of the district court was therefore affirmed. View "Bowles v. SSRG II, LLC" on Justia Law

Luther Poynter was incarcerated at the Barren County Detention Center in Kentucky for contempt of court related to unpaid child support. After a brief period in COVID-19 observation, he was moved to a general-population cell with two other detainees, Scotty Wix and Timothy Guess. Both Wix and Guess had extensive histories of violent behavior and multiple documented assaults against other detainees while in the facility. Shortly after Poynter entered the cell, Guess and Wix attacked him without apparent provocation, causing a traumatic brain injury and lasting physical impairment.The United States District Court for the Western District of Kentucky reviewed the case after Poynter, through his guardian, sued the jailer and Barren County under 42 U.S.C. § 1983, alleging deliberate indifference to his safety in violation of the Due Process Clause of the Fourteenth Amendment. The district court granted summary judgment to the county, concluding there was insufficient evidence of a constitutional violation or municipal liability, and held that Poynter had not shown he was placed at a substantial risk of harm or that reasonable steps were not taken to abate that risk.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. The appellate court held that Poynter had presented sufficient evidence for a reasonable jury to find that Barren County had a custom of failing to properly classify detainees with violent histories, recklessly disregarded a known risk, and that this failure caused Poynter’s injuries. The Sixth Circuit clarified that municipal liability can attach even without identifying a specific individual as the violator, so long as the unconstitutional harm resulted from a municipal policy or custom. The Court of Appeals reversed the district court’s summary judgment and remanded the case for further proceedings. View "Poynter v. Bennett" on Justia Law

The plaintiffs in this case are mental health counselors who provide “talk therapy” services, including counseling to minors, guided by their Catholic faith. Their services consist exclusively of spoken words, and they do not use physical or aversive techniques. Some of their clients, including minors with parental consent, seek counseling to address issues related to gender identity or sexual orientation, such as wanting to align their gender identity with their biological sex or to reduce same-sex attraction in accordance with their religious beliefs. The plaintiffs assert an ethical and religious duty to help clients pursue such goals if requested.In 2023, Michigan enacted laws forbidding licensed therapists from engaging in “conversion therapy” with minors, defined as efforts to change an individual’s sexual orientation or gender identity, but specifically permitting counseling that assists with gender transition. The plaintiffs filed suit in the United States District Court for the Western District of Michigan, seeking a preliminary injunction to block enforcement of these laws, arguing that the prohibition restricts their speech based on its content and viewpoint in violation of the First Amendment. The district court denied the motion, reasoning that the counseling in question was conduct, not speech, for constitutional purposes.On appeal, the United States Court of Appeals for the Sixth Circuit found that the plaintiffs had standing and disagreed with the district court’s characterization of the therapy as conduct rather than speech. The court held that the Michigan law is a content- and viewpoint-based restriction on speech and is therefore subject to strict scrutiny under the First Amendment. The court determined that the State did not demonstrate a sufficient justification for the restriction, and that the plaintiffs are likely to succeed on the merits of their claim. The Sixth Circuit reversed the district court’s denial of the preliminary injunction and remanded for prompt entry of an injunction preventing enforcement of the law during the case. View "Catholic Charities of Jackson v. Whitmer" on Justia Law

An inmate serving an indeterminate sentence of 45 years to life for first degree murder challenged the calculation of the timing for his initial youth offender parole hearing. His main contention was that under California law, youth offenders like himself should be entitled to the same categories of prison conduct credits to advance their parole hearing date as are available to other indeterminately sentenced inmates. Specifically, he argued that the California Department of Corrections and Rehabilitation (CDCR) unfairly limited the use of credit categories for youth offenders, allowing only educational merit credits (EMCs) to count towards advancing the youth parole eligible date (YPED), while non-youth inmates could use a broader range of credits to accelerate their minimum eligible parole date (MEPD).The Marin County Superior Court previously denied his habeas petition. After the California Supreme Court granted review and transferred the case back to the California Court of Appeal, First Appellate District, Division Four, with instructions to issue an order to show cause, the matter was reconsidered. The focus of the appeal was whether the CDCR’s regulations violated statutory or constitutional rights by distinguishing between youth and non-youth offenders in the application of parole-advancing credits.The California Court of Appeal, First Appellate District, held that the CDCR’s distinction did not violate statutory or constitutional principles. The court found that the regulatory scheme giving only EMCs to youth offenders for YPED calculations, while affording more credit categories for MEPD calculations for other inmates, was rationally related to legitimate governmental objectives, including administrative efficiency and the structure of the youth parole scheme. The court also rejected due process and equal protection arguments, applying rational basis review, and concluded that the distinction was constitutionally permissible. The petition for habeas corpus relief was denied and the petition discharged. View "In re Thai" on Justia Law